Privacy Notice for Online Activities

Online Privacy Notice

Privacy notice for online activities.

Presented by Legacy Real Estate Development, LLC and its affiliated entities, this Online Privacy Notice applies to the personal information collected from visitors to legacyrealestatedev.com websites, applications, and other online services linked to this notice.

For those seeking, applying for, or obtaining financial products and services for personal, family, or household purposes, the information collected by Legacy is governed by our U.S. Personal Investor Privacy Notice.

To access our Privacy Notice for California residents, please click here

Legacy's is Determined to Protect Investors

Placing not only their funds but also their personal and financial details in our trust, investors with Legacy acknowledge that our relationship is built on trust. We are determined to act responsibly and in the best interests of our investors. When it comes to divulging client or prospective client information, whether it involves the investor’s personal details or the acknowledgment of their association with Legacy, we adhere to the guidelines outlined in this policy.

Utilizing the investor’s personal information is primarily done to address their inquiries or requests, safeguard and manage their accounts, process submitted transactions, meet our legal obligations, conduct research and analysis, and develop, offer, and provide the financial products and services sponsored by Legacy.

Collecting Data from our Investors

The specific product or service an investor engages with determines the types of personal information Legacy gathers and shares. Among the potentially collected details are the investor’s name and address, Social Security or taxpayer identification number, date of birth, assets, income, account balances, and investment activity, obtained through interactions with our website.

When completing an account application with Legacy, investors provide personal information. (If entering information in an online account application, we may retain it even if the investor doesn’t finalize or submit the application.) Disclosing personal information also occurs when investors seek information or materials, engage with Legacy in various ways, participate in transactions within their accounts, or attend virtual events.

In addition to the personal information provided directly by investors, Legacy may receive authorized details from other parties. Identity verification, fraud prevention, and identification of potentially interesting products and services may lead Legacy to obtain personal information from non-affiliated service providers. The information collected may be transmitted or stored by Legacy or service providers in the United States or elsewhere, complying with legal requirements.

Legacy may integrate information from its website or mobile application with data collected in various contexts. This combination may include online information (via cookies or email exchanges) and offline sources (such as when establishing an account or contacting customer service). The handling of such combined information aligns with this policy. Opting not to provide information to Legacy may impact our ability to offer certain products or services.

What Is the Process of Using Investor Data?

As an investor, Legacy may use and share the investors’ personal information when necessary to fulfill transactions at the investors’ request, provide services, inform the investors about financial products and services offered, or market/advertise its products and services.

Particulars

To carry out specific transactions or account changes as per the investors’ instructions, Legacy may need to share identifying information about the investors with non-affiliated entities. For instance, if the investors request an asset transfer from another financial institution to Legacy, certain details about the investors, including but not limited to their names and relevant account information, will be shared with that institution to complete the transaction.

To inform the investors about other financial products and services sponsored by Legacy, their information may be shared within the Legacy family of affiliated companies, to the extent permitted by law. This may include sharing contact information and details about their current product and service usage within Legacy to make them aware of new investment offerings, advice & consulting services, or asset management and trust services.

At the direction of a retirement plan sponsor, client, plan, and/or participant information may be provided to third parties, such as service providers of the plan or the plan sponsor.

Legacy may contract with service providers to perform services, and when necessary and in line with legal requirements, may disclose the investors’ personal information to these service providers, or the investors may provide certain personal information directly to them. In such cases, Legacy provides the service providers with information only as needed to carry out their responsibilities as outlined in the agreement, and solely for that purpose. Legacy ensures these service providers treat the investors’ information with the same high degree of confidentiality.

To market its products and services, Legacy engages non-financial companies to display relevant advertisements while the investors browse other websites or use social media. Refer to the section titled Interest-Based Advertising below for more information on these activities.

Finally, Legacy will release information about prospective, current, or former customers based on the investors’ direction or authorization, if compelled by law or legal process, to comply with regulatory or legal requirements, or in other legally restricting circumstances.

Cookie Policy & Web Privacy

Safeguarding the privacy of our investors and potential investors is paramount, extending seamlessly to users of our Agora Real Estate investors’ portal, https://legacyrealestatedev.portal.agorareal.com/#/login?redirectUrl=%2F, and any other Legacy investors’ application.

Employing highly secure online communication methods, including data encryption, transmission encryption, usernames and passwords, adaptive authentication techniques, and back-end fraud and account monitoring, our Agora Real Estate investors’ portal provides a robust level of security and privacy for investors accessing their account information, conducting online transactions, or securely communicating.

Our approach involves utilizing various online technologies, detailed below, to gather insights into how investors engage with our corporate website, as well as our Agora Real Estate investors’ portal, and any other application that Legacy uses. When interacting with Legacy online, investors’ technical and navigational details are automatically collected through these technologies by us or our service providers. This information encompasses, as applicable: computer or device type; operating system version; browser type and version; user agent string; internet connection type; mobile network provider; date and time of visit; time since the last visit; pages viewed; links selected; searches conducted; internet protocol (IP) address used to access our website or mobile application; general geographic location (e.g., city, state, or zip code); and the website visited before ours. Additionally, similar tracking technologies may be incorporated in emails sent by us or our service providers to investors, as outlined below. The gathered information serves diverse purposes, including alerting investors to software compatibility issues, resolving technical or service problems, and enhancing security. Analyzing this information, with the support of our service providers and within legal compliance, aids in refining our website and mobile application design and functionality, enhancing our capability to serve investors.

A cookie is a small data file comprising letters and numbers that gets stored on your computer or other devices when you visit a website or a mobile application. These cookies contain information that is either transferred to or read directly from your device, enabling websites and mobile apps to identify devices and retain specific information, like user preferences. The primary purpose of cookies is to differentiate investors from other users of our online services. This distinction aids in personalizing and enhancing the investor’s experience, improving site navigation, and facilitating the development, offering, and provision of our products and services. Additionally, cookies play a crucial role in helping us comprehend how investors utilize our online services, thereby allowing us to enhance their structure, functionality, security, and content.

Both session cookies and persistent cookies are utilized for this purpose. Session cookies connect the investor’s actions during a specific online session and expire once that session concludes. Persistent cookies, on the other hand, remain on the investor’s device, enabling us to recall their actions or preferences across multiple browser sessions.

If you, as an investor, have concerns about the presence of cookies on your computer or device, you can configure your web browser settings to either reject all cookies or notify you when a cookie is being set, allowing you to decide whether to accept it. Furthermore, you have the option to delete cookies from your device. The help feature on most web browsers provides information on how to prevent your browser from accepting new cookies, receive notifications when a new cookie is set, or disable cookies altogether. However, it’s important to note that opting to block or delete cookies may lead to certain features of our Legacy website or mobile application not functioning correctly.

Transparency with our Analytics Software

We enlist the services of third-party providers to gather information as outlined above, aimed at conducting analysis, auditing, research, and reporting. These providers have the capability to set and access cookies on your device and utilize web beacons to track your activity on our website or mobile application.

Adobe Analytics: Our website and mobile application employ Adobe Analytics to collect and analyze specific information for the aforementioned purposes. Data generated from your use of our online services may be sent to and stored by Adobe Analytics on servers located outside your country of residence.

Google reCAPTCHA: We have incorporated Google reCAPTCHA (“reCAPTCHA”) on select websites to enhance the security of your online accounts and prevent fraudulent activities. This service is provided by Google LLC. We use reCAPTCHA to verify whether an input originates from a natural person or automated technology. reCAPTCHA analyzes and gathers specific personal information about website visitors, including but not limited to: IP address, cookies, mouse movements, and duration of stay on the website. Through the use of reCAPTCHA, your personal data may be transmitted to Google and other third parties to confirm that you are a human user and not an automated processor or spam bot. The utilization of reCAPTCHA is governed by Google’s Privacy Policy and Terms of Service.

Interest-Based Advertising

We also collaborate with service providers, including social networks, to deliver targeted advertising services tailored to your online activities over time and across various unrelated websites (Interest-Based Advertising). This collaboration also aids in measuring brand awareness and evaluating the effectiveness of our online advertising efforts. These service providers may employ cookies, web beacons, and similar technologies to gather information about your interactions on our website, potentially combining it with data from your activities on other unaffiliated websites.

Both we and our service providers may leverage data collected on our website or when you open emails from Legacy, along with additional information about you and your Legacy relationships, to present Legacy advertisements on their platforms and other websites as you navigate the internet. For instance, we may share your email address with our advertising service providers to facilitate the targeting of Legacy products and services ads on non-Legacy websites. Furthermore, our advertising service providers may utilize information obtained during your use of our online services, including limited demographic details (such as age), to optimize the targeting of non-Legacy advertisements based on your overall online activity.

We may utilize technologies provided by service providers that enable us to establish connections among associated devices, such as smartphones, tablets, and computers. This means that information about your interactions with our online services and online advertising across different devices may be consolidated. Through these connections, we aim to gain a better understanding of the relevance of our content and the impact of our advertising, allowing us to customize content and improve the overall user experience.

Protecing Informaiton

Within Legacy, access to information about the investor and/or client is limited to those Legacy employees who require the information for job-related tasks, such as servicing your accounts, providing requested information, or informing you about new products and services. To ensure the confidentiality of your personal information, we implement physical, electronic, and procedural safeguards in accordance with industry standards. These safeguards are regularly reviewed and adjusted in response to technological advancements. For a more in-depth understanding of our online security and privacy features, please refer to our Security Center.

It is vital for the investor and/or client to safeguard their account information. For your protection, avoid sharing your account details, username, or password with anyone. If investors come across any suspicious activity related to their accounts or suspect fraud, please reach out to us at investor@legacyrealestatedev.com

Reviewing your account information with Legacy is convenient. We offer various options for accessing and reviewing your account details, including statements, account documents, automated phone services, and our website. Additionally, investors can request information by writing or calling us. Specific website addresses, mailing addresses, and phone numbers are provided on your account statements and other Legacy correspondence.

We will inform investors and/or clients of our online privacy notice as required by law. We reserve the right to modify this policy at any time. However, please be assured that if any changes are made, we will promptly notify you.

Offices

1691 Michigan Ave, Miami Beach, FL 33139

712 5th Ave, New York, NY 10019

1100 15th St NW Washington, DC 20005

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Online Privacy Notice